Privacy Notice

Privacy Notice

 

1. Introduction 

Alto’s mission is to make home care easier; that means making it safer, more affordable, and more convenient. We work to fulfil this mission by making available online communication tools, information, and an extended network of Careseekers and Caregivers that help our users find and coordinate quality care for children, seniors, individuals with special needs, and care for the home. 

The Alto Privacy Notice is designed to provide a clear understanding of the information we collect, how we use it, and to whom we disclose it to help fulfil our mission and provide users with a better experience. 

This Privacy Notice applies to your use of this Platform and our Services and is an agreement between you and Alto regarding the collection, storage, use and disclosure of your Personal Information. Please read it carefully. You consent to the terms of this Privacy Notice by browsing our Platform or using our Services. You thereby consent to the collection, storage, use and disclosure of your Personal Information in accordance with the terms of this Privacy Notice.

2. Overview 

This Privacy Notice describes how Alto and its affiliates collect and use personal data. This Privacy Notice applies to all users of our apps, websites, features, or other services anywhere in the world and specifically to Caregivers and Careseekers. 

As you continue to read our Privacy Notice please keep the following definitions in mind:

  • “Caregivers” means professionals that provide in-home services;

  • “Careseekers” means individuals seeking care;

  • “Alto”, “we”, “us”, and “our”, are our affiliated companies and service providers that assist us in providing the Services and Platform to you;

  • “Privacy Notice” means this Privacy Notice, as it is amended and restated from time to time;

  • “Non Personal Information” is information that cannot be used to contact or identify you and is not linked to information that can be used to contact or identify you. It can include passively collected information about your activities on our Platform, such as usage data, but only to the extent that information is not linked to your Personal Information;

  • “Personal Information” means information that can be used to contact or identify you and information that is linked to such information. It is information about an identifiable individual.  

  • “User” means individuals who register with Alto to use the Platform or Services;

  • “Services” means any services we offer through the Platform or any other channels;

  • “Platform” means our website at www.Alto.com and any Canadian affiliated websites, web pages, mobile applications and mobile websites;

  • “You” or “your” refers to you, as a visitor or User of the Platform or the Services;

We collect information from you and about you when you use our Platform and our Services, when you communicate with us through the Platform, Facebook or other methods, when you communicate with other users of our Platform, and when other people communicate with us about you.

IF YOU USE THE SERVICES ON OUR PLATFORM, you consent to the collection of information from third parties, which may include Personal Information, to verify information that you provide to us and to verify certain representations and warranties that you make to us. If you do not want us to perform verification checks, please do not use the Services on our Platform.

We use advertising technologies (cookies, web beacons and other technologies) that use segment information (such as the type of care that you are interested in) in order to tailor advertising to your inferred interests. Please see the description of our practices below and how to opt-out.

As an online venue for Careseekers and Caregivers to connect, arrange care, and share advice, the information that you post to the Platform or submit using the Services may be shared with and used by other users and Platform visitors. 

We use the Personal Information we collect about you in order to provide Services to Users and Platform visitors, and to improve our Platform and Services.

We also use your Personal Information for marketing purposes. Please see below for your marketing opt-out rights. We may share your Personal Information with affiliates and third-party service providers who assist us in providing Services to you including this Platform. These third-party service providers may be located outside of Canada and, therefore, your Personal Information may become subject to the laws of those other jurisdictions. Please see below for our specific data use practices.

When we share your Personal Information with our affiliates and third-party service providers, they are required to use your Personal Information only for the purpose of assisting us. However, as described below, we may disclose your Personal Information to others in certain circumstances if required or permitted by law.

3. Data Collection, Uses and Information We Collect

Alto collects Personal Information: 

  • provided to Alto, such as during account creation

  • created during use of our services, such as location, app usage, and device data

  • from other sources, such as other Users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities

The following Personal Information is collected by or on behalf of Alto:

3.1 User Profile 

We collect data when Users create or update their Alto accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license or other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes emergency contact information and User settings to provide services using Alto Platform or Services. 

This also includes gender and/or occupation (when required for certain Alto services).

We will also use the photos submitted by Users to verify their identities, such as through facial verification technologies. 

3.2 When Posting a Job 

If you are a Careseeker, we collect and store all of the additional information that you provide on your booking request. This may include, among other information: the type of care you are looking for, schedule, location, hourly rate, narrative job description, requirements for a Caregiver (such as ability to drive); pictures; and any other information you choose to include in your booking request.

3.3 When Creating a Caregiver Profile

If you are a Caregiver, we collect and store all of the additional information that you provide to us in your profile. This may include, among other information: details on the care you offer, including for example the type of care you provide, your availability, your location, your level of education, languages you speak, your ability to drive; related services you provide; pictures; your phone number; references, if you choose to provide them; any other information you choose to include in your profile.

3.4 Background Checks and Identity Verification 

In order to increase the quality of our service and to further develop trust amongst our users; Alto performs verification checks on our registered Caregivers. Verification checks require a photo of a valid government issued piece of photo identification, a photo of a valid criminal record check including the vulnerable sector from your municipal police department or the RCMP that is no more than three months old from the date of submission, a photo of valid CPR and First Aid certification from any Canadian accredited organization, and photos of any other relevant educational credentials as necessary. The documents provided for the verification checks are kept confidential and are not shared beyond the Alto employees who perform the verification checks.

3.5 Demographic data

We may collect demographic data about Users, including through User surveys.  We may also infer demographic data from other data collected from Users. 

3.6 User Content 

We collect the data submitted by Users when they contact Alto customer support, provide ratings or compliments for other Users, restaurants or merchants, or otherwise contact Alto. This may include feedback, photographs or other recordings collected by Users, including audio or video recordings submitted by Users in connection with customer support. This also includes metadata relating to the method you use to communicate with Alto.

3.7 Location Information

Location data (Caregiver and Careseeker): We collect Caregivers’ and Careseekers’ geolocation information (e.g., your approximate location based on IP address, or precise location with your consent) including to enable care and services to be delivered, to prevent and detect fraud, and to satisfy legal requirements.  Alto collects this data when users access the Alto Platform or its Services. We collect such data from users if they enable us to do so.  

3.8. By Platform Visitors, Users and others

We may also collect information that you, other users of the Platform and others provide about each other. For example, this occurs when Caregivers are rated or reviewed, when a Careseeker creates a profile for someone other than themselves, when we obtain references on a Caregiver, when Users communicate directly with each other, and when we receive information about Users by phone, email or postal mail.

3.9 By third parties to verify your information, representations, and suitability for Alto

By using our Services, you agree that we may request verification checks using your Personal Information in accordance with our Terms of Use. If we perform verification checks, we perform them to verify the information you provide us (such as your name, address, email address, etc.), the representations and warranties you make in the Terms of Use and on the Platform (such as representations regarding your criminal background), and your suitability for Alto The results of these verification checks are made available to Alto.

We may use third-party service providers to perform these verification checks. Our third-party service providers may conduct verification checks against a variety of materials which, subject to applicable law, may include but not limited to media streams, terrorist watch lists, criminal and fugitive watch lists, fraud watch lists, law enforcement reports, criminal databases, sex offender registries and other data to perform these verification checks.

3.10 By other sources

We also collect and combine information with your Personal Information from publicly available sources. We also combine statistical demographic information with your Personal Information. We use this information to enable us to comply with regulatory requirements, ensure the accuracy of data, better understand your likely interests, prevent fraud, and for other purposes permitted by law. Also included and are not limited to: 

  • Users participating in our referral programs. For example, when a User refers to another person, we receive the referred person’s personal data from that User.

  • Alto account owners who request services for or on behalf of other Users, or who enable such users to request or receive services through their accounts. 

  • Users or others providing information in connection with claims or disputes.

  • Alto business partners through which Users create or access their Alto account, 

  • vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements 

  • insurance, vehicle, or financial services providers for Caregivers and Careseekers 

  • partner transportation companies

  • publicly available sources

  • marketing service providers or data resellers whose data Alto uses for marketing or research

  • law enforcement officials, public health officials, and other government authorities

Alto may combine the data collected from these sources with other data in its possession.

3.11 Transaction information

We collect transaction information related to the use of our Services, including the type of services requested or provided, order details, payment transaction information, service delivery information, date and time the service was provided, amount charged, distance travelled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

 3.12 Usage data

We collect data about how Users interact with our Services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing.In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Policy. 

3.13 Device data

We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

3.14 Communications data

We enable Users to communicate with each other and Alto through Alto’s Platform and Services. For example, we enable Caregivers and Careseekers to message each other. To provide this service, Alto receives some data regarding the communications, including the date and time of the communications and the content of the communications. Alto may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics.

4. How we use Personal Infomation

Alto uses Personal Information to enable reliable, convenient and safe care and other products and services. We also use such data:

  • to enhance the safety and security of our Users and Services

  • for customer support  

  • for research and development  

  • to enable communications between Users 

  • to send marketing and non-marketing communications to Users

  • in connection with legal proceedings

This includes using data to:

  • create/update accounts

  • enable care services (such as using location data to facilitate care service), features that involve data sharing and accessibility features to facilitate use of our services by those with disabilities

  • process payments

  • track and share the progress of Services 

  • personalize Users’ accounts

  • perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

4.1. Safety and Security

We use personal data to help maintain the safety, security, and integrity of our Services and Users. This includes:

  • verifying Users' identity and eligibility to provide care services, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe Caregivers or Careseekers

  • using device, location, User profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our Services by unauthorized Caregivers or Careseekers, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to Users’ accounts.

  • using User ratings, reported incidents, and other feedback to encourage compliance with our community guidelines and as grounds for deactivating Users providing poor quality of care or who otherwise violated such guidelines.  

Alto performs the above activities on the grounds that they are necessary to fulfil our obligations to Users under our Terms and Conditions or other agreements with Users, and/or for purposes of the legitimate safety and security interests of Alto or other parties, including Users and members of the general public.

4.2 Customer Support

Alto uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

4.3 Research and Development

We may use personal data for testing, research, analysis, product development, and machine learning to improve the User experience. This helps us make our Services more convenient and easy-to-use, enhance the safety and security of our Services, and develop new Services and features.

4.4  Enabling Communications between Users

For example, a caregiver may message a Careseeker to confirm a service location, a Careseeker may contact a Caregiver to discuss the care provided.  

4.5 Marketing

Alto may use personal data to market our services to our Users. This includes sending Users communications about Alto services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in app communications and ads, and ads on third party platforms.

We may also inform Users about products and Services offered by Alto partners. For example, we may provide recommendations, promotions, or ads for Alto partners based on Users’ past service orders. Although we inform Users about products and services offered by Alto partners, we do not sell Users’ Personal Information to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with Users’ consent.

We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off Alto’s apps and websites, including based on User location, use of Alto’s services, and User preferences and settings.

Alto performs the above activities on the grounds that they are necessary for purposes of Alto’s legitimate interests in informing Users about Alto services and features or those offered by Alto’s partners, or on the basis of user consent. 

4.6  Non-Marketing Communications

Alto may use Personal Information to generate and provide users with receipts; inform them of changes to our terms, Services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Alto or its partners.

4.7 Legal Proceedings and Requirements

We may use Personal Information to investigate or address claims or disputes relating to use of Alto’s Services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.

Alto performs the above activities on the grounds that they are necessary for purposes of Alto’s legitimate interests in investigating and responding to claims and disputes relating to use of Alto’s services and features, and/or necessary for compliance with applicable legal requirements.

4.8  Disclosure of Personal Information 

By using our Services, you agree that we may disclose your Personal Information to third parties for use by those third parties. Please see above regarding sharing your Personal Information with visitors and Users of the Platform.

We may also disclose your Personal Information without your consent if required or permitted by the Personal Information Protection and Electronic Documents Act (Canada) or substantially similar applicable provincial legislation.

For example, we may disclose your Personal Information in emergencies if it is clearly in your interests and consent cannot be obtained in a timely way. We may also disclose your Personal Information to collect a debt from you or to comply with a subpoena, warrant or order issued or made by a court, person or body with jurisdiction to compel the production of personal information. This includes disclosure in any legal proceeding to protect or defend Alto’s or a third party’s rights or property. We may disclose your Personal Information to a public body or a law enforcement agency in Canada concerning an offence under the laws of Canada or a province (including to protect our property or the health, safety and property of our community), to assist in an investigation or in the making of a decision to undertake an investigation. We may also disclose your personal information if it is otherwise required or authorized by law.

4.9 Non-Personal Information

We may disclose any Non Personal Information collected about you, provided it is in a de-identified form for any commercial purpose.

4.10 Business transactions

We may disclose and transfer your Personal Information and Non-Personal Information in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Alto or its affiliates or as part of a corporate reorganization or change in corporate control.

5. Data Sharing and Disclosure

Some of Alto’s Services and features require that we share Personal Information with other Users or at a User’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

5.1. At the User’s request

This includes sharing data with:

  • Other people at the User’s request

  • Alto’s business partners. For example, if a User requests a service through a partnership or promotional offering made by a third party, Alto may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; suppliers or services; those with an API or service with which we integrate.

  • Emergency services: We offer features that enable Users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.  

5.2 With the General Public 

Questions or comments from Users submitted through public forums such as Alto blogs and Alto social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a User.

5.3 With the Alto Account Owner

If a User requests care or services using an account owned by another party, we may share their order or trip information, including location data, with the owner of that account. 

5.4 With Alto Subsidiaries and Affiliates

We share Personal Information with our subsidiaries and affiliates to help us provide our Services or conduct data processing on our behalf. 

5.5 With Alto Service Providers and Business Partners

Alto provides Personal Information to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

  • payment processors and facilitators

  • background check and identity verification providers

  • cloud storage providers

  • Google, in connection with the use of Google Maps in Alto’s apps (see Google’s privacy policy for information on their collection and use of data)

  • social media companies, including Facebook, in connection with Alto use of their tools in Alto’s Platform and services (see Facebook’s privacy policy for information on their collection and use of data)

  • Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our Users and measure advertising effectiveness

  • research partners, including those performing surveys or research projects in partnership with Alto or on Alto’s behalf

  • vendors that assist Alto to enhance the safety and security of its apps

  • consultants, lawyers, accountants, and other professional service providers

  • insurance and financing partners

5.6 For Legal Reasons or in the Event of a Dispute

Alto may share Users’ Personal Information if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing Personal Information with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Alto’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your Personal Information.  

This also includes sharing Personal Information with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

5.7 With Consent

Alto may share a User’s Personal Information other than as described in this notice if we notify the User and they consent to the sharing.

6. Your Communication Choices

We are an on-line business. Therefore, we need to be able to communicate with our Users through electronic communications. By becoming a User, you consent to receive electronic communications from us. Please note that you may not opt-out of certain emails regarding Alto. These include notices of updates to our Privacy Notice, responses to booking requests from Caregivers, and bookings from Careseekers if we choose to provide such notices to you in this manner.

You may opt-out of certain electronic communications. For example, you can opt-out of receiving further promotional communications from us by following the unsubscribe instructions provided in the promotional e-mail.

Alto uses third-party advertising companies which use technologies such as cookies. If you prefer not to receive these advertisements, you may opt-out.  Please also note that in order for the opt-out to work your browser must be set to accept third-party cookies. Furthermore, if you buy a new computer or mobile device, change web browsers or delete the opt-out cookie, you will need to perform the opt-out task again.

7. Accessing, Changing or Removing your Personal Information and Closing your Account

You may access, change, or remove Personal Information you provided when you registered by logging into your account and accessing your account settings. You can remove some of the Personal Information you have posted on the Platform, such as information you posted in profiles and job postings, by editing or deleting that item in the profile or jobs area of your account.

Personal Information that you post may have been captured and archived by search engines. This Personal Information (including job postings) may remain searchable on the Internet even after you or we delete it.

If you no longer wish to participate in our Services you may contact customer support and request that your account be closed. If your Alto account is closed, we will remove your name and other Personal Information from our publicly viewable database. Please note that we may delete any or all of your account information, which includes Personal Information, without liability unless otherwise specifically provided by applicable law.

We will retain your Personal Information if we believe it may be necessary to prevent fraud or future abuse. We may also retain your Personal Information and Non-Personal Information for business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, auditing our records, enforcing our rights and obligations under our agreements or if required by law. Alto may also retain and use your information if necessary to provide the Services to other Users. For example, just as an email you may send to another person through an email service provider resides in that person’s inbox even after you delete it from your sent files or close your account, emails you send to others through Alto to other Users, may remain visible to others after you have closed your account. Similarly, other information you have shared with others, or that others have copied, may also remain visible. To the extent permitted by law, Alto disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information. Alto does not control when search engines update their cache, which may contain certain job post or profile information that has since been removed from Alto’s Platform.

8. How We Protect Information

We implement administrative, technical and physical security measures to protect your Personal Information that is not otherwise visible to Platform visitors. These include:

  • Alto uses strong encryption technology to protect sensitive information.

  • Alto employs firewalls and system monitoring to protect against unauthorized access of our systems.

If you are a User, you will be asked to create a password. You should create a strong password (one that uses letters and numbers or symbols and is not a dictionary word or name or includes information about you such as your date of birth or middle name). Please change your password frequently. If you access our Platform from a public computer, please ensure to fully log-out of the Platform and delete your browsing history and cache. If you access our Platform from your own computer, ensure that your computer is password protected.

9. Links to Other Web Sites

Alto may provide links to other web sites that we believe may be of interest to our Users. Please review the privacy policies of those other web sites. We are not responsible for the privacy practices employed by those websites, nor are we responsible for the information or content they contain. This Privacy Notice applies solely to information collected by us through Alto.

10. Changes to Our Privacy Notice

We may change any or all of the provisions in this Privacy Notice from time to time. We will notify you about significant changes in the way we treat Personal Information by sending a notice to the email address registered in your account, or by placing a prominent notice on our Platform, so that you can choose whether to continue using our Services. Significant changes will go into effect 30 days after we provide notice. Non-material changes or clarifications will take effect immediately upon posting of the updated policy on our Platform. You should periodically check Alto for updates. Your continued use of the Platform or the Services after such an effective date will constitute acceptance by you of such changes.